Privacy Policy

1 Introduction

topjili ("we", "us", "our") operates the online gaming platform available at topjili.vip. We are committed to protecting the privacy and personal data of all players and visitors who use the topjili platform. This Privacy Policy describes how topjili collects, uses, stores, shares, and protects your personal information.

This Privacy Policy applies to all personal data collected through the topjili website, mobile application, customer support channels, and any other interaction you have with topjili. By registering an account or using the topjili platform, you acknowledge that you have read and understood this Privacy Policy.

This policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines.

2 Data Controller

topjili is the data controller responsible for the personal data collected through the topjili platform. As data controller, topjili determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable data protection laws.

If you have any questions about how topjili processes your personal data, or if you wish to exercise any of your data rights, you may contact our Data Protection Officer at: [email protected]

3 Personal Data We Collect

3.1 Registration Data

When you create a topjili account, we collect the following information:

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Philippine mobile number or email address
• Username and encrypted password
• Residential address (required for identity verification)

3.2 Identity Verification Data

To comply with anti-money laundering regulations and to verify your identity and age, topjili may collect:

• Government-issued identification documents (e.g., Philippine passport, driver's licence, SSS ID, UMID)
• Proof of address documents (e.g., utility bills, bank statements)
• Source-of-funds documentation where required by law
• Selfie or facial verification image for identity matching

3.3 Financial Data

When you make deposits or withdrawals, topjili collects:

• GCash or PayMaya mobile number
• Bank account details (for BPI, BDO, or Metrobank transfers)
• Transaction history, including deposit amounts, withdrawal amounts, and timestamps

topjili does not store full payment card numbers. All financial data is processed through secure, PCI-compliant payment processors.

3.4 Gaming Activity Data

topjili records all gaming activity on the platform, including:

• Games played, bets placed, and outcomes
• Session duration and frequency of play
• Bonus claims and wagering activity
• Responsible gaming tool usage (deposit limits, self-exclusion requests)

3.5 Technical Data

When you access topjili, we automatically collect certain technical information:

• IP address and approximate geographic location
• Device type, operating system, and browser version
• Pages visited, time spent on pages, and navigation paths
• Cookie identifiers and session tokens

3.6 Communications Data

When you contact topjili's support team, we collect records of your communications, including chat transcripts, email correspondence, and any information you provide in support tickets.

4 How We Collect Your Data

topjili collects personal data through the following means:

• Directly from you – when you register an account, complete identity verification, make a deposit or withdrawal, contact support, or participate in promotions.
• Automatically – through cookies, web beacons, and similar tracking technologies when you access the topjili website or mobile application.
• From third parties – from identity verification providers, payment processors, fraud prevention services, and regulatory authorities where permitted by law.

5 How We Use Your Personal Data

topjili uses your personal data for the following purposes:

• Account management: To create, maintain, and secure your topjili account.
• Age and identity verification: To confirm that you are 21 years of age or older and to verify your identity as required by law.
• Payment processing: To process deposits, withdrawals, and refunds in Philippine Peso.
• Gaming services: To provide access to topjili's games, betting markets, and promotions.
• Legal compliance: To comply with anti-money laundering laws, tax reporting obligations, and regulatory requirements applicable in the Philippines.
• Fraud prevention: To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct.
• Responsible gaming: To monitor gaming patterns and provide responsible gaming tools, including deposit limits and self-exclusion.
• Customer support: To respond to your inquiries and resolve disputes.
• Platform improvement: To analyse usage patterns and improve the topjili platform, games, and user experience.
• Marketing communications: To send you promotional offers and updates, where you have consented to receive such communications. You may opt out at any time.

6 Legal Basis for Processing

topjili processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between you and topjili, including account management, payment processing, and provision of gaming services.
• Legal obligation: Processing required to comply with applicable laws, including anti-money laundering regulations, age verification requirements, and tax reporting obligations.
• Legitimate interests: Processing for fraud prevention, platform security, and improvement of topjili's services, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

7.1 Service Providers

topjili shares personal data with trusted third-party service providers who assist in operating the topjili platform, including:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC (Know Your Customer) service providers who assist in verifying player identity and age.
• Fraud prevention services: Providers who help topjili detect and prevent fraudulent activity on the platform.
• Cloud infrastructure providers: Hosting and data storage providers who maintain the technical infrastructure of the topjili platform.
• Customer support platforms: Tools used to manage and respond to player support inquiries.

All third-party service providers engaged by topjili are contractually required to process personal data only on topjili's instructions and to maintain appropriate security measures. topjili does not permit service providers to use your data for their own purposes.

7.2 Regulatory and Legal Disclosure

topjili may disclose your personal data to government authorities, law enforcement agencies, or regulatory bodies where required to do so by applicable Philippine law, court order, or regulatory directive. This includes disclosures to the Anti-Money Laundering Council (AMLC) and other relevant Philippine authorities.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of topjili's business, your personal data may be transferred to the acquiring entity as part of the transaction. topjili will notify affected players of any such transfer and the privacy practices of the acquiring entity prior to the transfer taking effect.

7.4 No Sale of Personal Data

topjili does not sell, rent, or trade your personal data to third-party marketers or data brokers under any circumstances.

8 International Data Transfers

topjili primarily processes and stores player data within the Philippines. Where it is necessary to transfer personal data to service providers located outside the Philippines, topjili ensures that appropriate safeguards are in place to protect your data, including contractual data protection clauses consistent with the requirements of the Philippine Data Privacy Act of 2012.

By using the topjili platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines where topjili's service providers operate. topjili will take all reasonable steps to ensure that such transfers are conducted securely and in compliance with applicable data protection law.

9 Data Retention

topjili retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Identity verification documents: Retained for the duration of your account and for five (5) years following account closure.
• Gaming activity logs: Retained for a minimum of three (3) years.
• Support communications: Retained for two (2) years from the date of the last communication.
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter as evidence of consent.

Upon expiry of the applicable retention period, topjili will securely delete or anonymise your personal data in accordance with its data disposal procedures.

10 Cookies & Tracking Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device when you visit the topjili website. They allow topjili to recognise your device, remember your preferences, and improve your experience on the platform.

10.2 Types of Cookies We Use

• Strictly necessary cookies: Required for the topjili platform to function. These include session authentication cookies and security tokens. These cannot be disabled.
• Performance cookies: Collect anonymised data about how players use the topjili platform, helping us identify and fix technical issues and improve performance.
• Functional cookies: Remember your preferences, such as language settings and display options, to personalise your experience.
• Analytics cookies: Used to understand aggregate player behaviour and improve the topjili platform. Data collected is anonymised and not linked to individual players.

10.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the topjili platform. Strictly necessary cookies cannot be disabled as they are essential for the platform to operate securely.

11 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by topjili:

• Right to be informed: The right to be informed of how your personal data is collected, used, and stored, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data topjili holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to topjili's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another data controller.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe topjili has violated your data privacy rights.

To exercise any of these rights, please contact topjili's Data Protection Officer at [email protected]. topjili will respond to all data rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, and you will be notified accordingly.

12 Children's Privacy

The topjili platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine gaming regulations. topjili does not knowingly collect personal data from individuals under the age of 21.

If topjili becomes aware that personal data has been collected from a person under the age of 21, the account will be immediately suspended, the data will be deleted, and any deposited funds will be returned to the original payment method after deducting any winnings derived from wagers placed during the period of underage use.

If you believe that a minor has registered a topjili account, please contact us immediately at [email protected].

13 Security Measures

topjili implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the topjili platform.
• Encrypted storage of sensitive personal data, including passwords (stored as salted hashes) and identity documents.
• Two-factor authentication (2FA) available for all player accounts to prevent unauthorised access.
• Access controls: Personal data is accessible only to topjili staff who require it to perform their job functions, on a strict need-to-know basis.
• Regular security audits and penetration testing of the topjili platform and infrastructure.
• Incident response procedures to detect, contain, and respond to data security incidents promptly.

While topjili takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for keeping your topjili account credentials confidential and for notifying topjili immediately if you suspect unauthorised access to your account.

14 Third-Party Links

The topjili platform may contain links to third-party websites or services. This Privacy Policy applies solely to the topjili platform and does not cover the privacy practices of any third-party websites. topjili is not responsible for the content or privacy practices of third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

15 Updates to This Privacy Policy

topjili reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. When material changes are made, topjili will notify registered players via email or an in-platform notification at least seven (7) days before the changes take effect.

The most current version of this Privacy Policy will always be available at topjili.vip/privacy-policy, with the effective date clearly indicated at the top of the document. Your continued use of the topjili platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy.

16 Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or topjili's data processing practices, please contact our Data Protection Officer:

If you are not satisfied with topjili's response to your complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. For more information on filing a complaint, visit the National Privacy Commission's official website.

For responsible gaming concerns, please visit our Responsible Gaming page for tools and resources to help you manage your gaming activity.